Collectors have until May 9 to comment on a proposed renewal of the current Memorandum of Understanding between the United States and Greece that could impact some popularly collected ancient coins. 

Ancient Coin Collectors Guild board member Peter Tompa advised, “Coin collectors in particular should comment to help protect the current exemption for ancient trade coins struck in Greece. Such coins — which include Athenian Tetradrachms, Corinthian Staters and Tetradrachms and gold coins of Philip and Alexander the Great — are very popular with collectors.”

The Memorandum of Understanding between the Government of the United States of America and the Government of the Hellenic Republic Concerning the Imposition of Import Restrictions on Categories of Archaeological and Byzantine Ecclesiastical Ethnological Material through the 15th Century A.D. of the Hellenic Republic will be reviewed by the Cultural Property Advisory Committee. 

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The easiest way for collectors to make public comments is by visiting the Federal eRulemaking Portal and entering Docket No. DOS-2016-0009 for Greece. The deadline for comments is 11:59 p.m. May 9. 

Tompa notes that public comments are not limited to U.S. citizens, adding, “Comments from collectors from Greece are particularly welcome!”

What to say

Tompa suggests that collectors write a brief, polite explanation about why the renewal should be denied or limited, considering several points. Specifically, that while the restrictions in the MOU are only to be applied on artifacts first discovered in Greece, ancient coins circulated extensively outside of the current Greek nation state. He adds, “The governing statute requires restrictions only be placed on artifacts of ‘cultural significance.’ But coins — which exist in many multiples — do not meet that particular criteria.” 

Further, Tompa writes that while the restrictions are intended to assist in international cultural exchanges, “restrictions diminish the ability of American collectors (particularly Greek Americans) to appreciate Greek culture and greatly limit people to people contacts with other collectors in Europe.” 

During the last public hearing on the MOU in October 2010, 10 speakers from the public spoke in favor of the proposed MOU while eight expressed reservations about the MOU or the extension of import restrictions to coins. Those supporting the import restrictions spoke of the severity of looting in Greece that hurts the ability of researchers today to learn about ancient cultures. Those who questioned the viability of the MOU wondered if Greece had the ability to care for its own cultural property. Prior to that hearing, 1,347 comments were posted online and approximately 70 percent opposed the MOU completely or in part. 

If any common thread ran throughout the hearing, it was that the MOU and the Cultural Property Advisory Committee needed to better define what is Greek, since the borders of ancient cultures do not neatly line up with modern nation state boundaries. The resulting MOU was announced in the Dec. 1, 2011, Federal Register, and is in force for five years, after which it may be renewed. 

The current MOU includes three broad categories of coins, including many small denomination coins that are commonly collected: 

a. Greek Bronze Coins — Struck by city-states, leagues, and kingdoms that operated in territory of the modern Greek state (including the ancient territories of the Peloponnese, Central Greece, Thessaly, Epirus, Crete and those parts of the territories of ancient Macedonia, Thrace and the Aegean islands that lay within the boundaries of the modern Greek state). Approximate date: fifth century B.C. to late first century B.C. 

b. Greek Silver Coins — This category includes the small denomination coins of the city-states of Aegina, Athens, and Corinth, and the Kingdom of Macedonia under Philip II and Alexander the Great. Such coins weigh less than approximately 10 grams and are known as obols, diobols, triobols, hemidrachms, and drachms. Also included are all denominations of coins struck by the other city-states, leagues, and kingdoms that operated in the territory of the modern Greek state (including the ancient territories of the Peloponnese, Central Greece, Thessaly, Epirus, Crete, and those parts of the territories of ancient Macedonia, Thrace and the Aegean islands that lie within the boundaries of the modern Greek state). Approximate date: sixth century B.C. to late first century B.C. 

c. Roman Coins Struck in Greece — In silver and bronze, struck at Roman and Roman provincial mints that operated in the territory of the modern Greek state (including the ancient territories of the Peloponnese, Central Greece, Thessaly, Epirus, Crete, and those parts of the territories of ancient Macedonia, Thrace and the Aegean islands that lie within the boundaries of the modern Greek state). Approximate date: late second century B.C. to third century A.D. 

The 2011 Federal Register notice stated, “The importance and popularity of such items regrettably makes them targets of theft, encourages clandestine looting of archaeological sites, and results in their illegal export and import.” Large denomination Greek silver trade coins as well as all Greek gold coins were excluded from the import restrictions, but Tompa and other collectors remain concerned that they may be included in the current renewal. 

The proposed renewal will be discussed at a May 24 to May 26 meeting of the Cultural Property Advisory Committee. An open portion of the meeting to receive oral public comments on the proposals to extend the Greece MOU will be held on May 24 beginning at 9:30 a.m. Those who wish to attend should notify the Cultural Heritage Center of the U.S. Department of State at 202-632-6301 no later than 5:00 p.m. on May 9 to arrange for admission; seating is limited.